The arranged financing programs absolutely need to be reported as in this proposal regardless of possible “costs” anticipated. How else will we know what baskets of complex TRS type swaps contain the shares we rightfully own but have been hidden so as to hide FTDs.

" Publication of Short Interest for Exchange-listed Equity Securities" Why are firms are currently allowed to hold any unreported open short positions? In the OTC market, one firm's large short position could potentially destroy a company. " Content of Short Interest Data" The more data points you collect and publish, the better. A free and fair market means transparency for everybody. There's no reason firms should have access to every dimension of information, while they themselves remaining vague.

FINRA, you have big name institutions that have in the past been found violating regulations on how to properly mark a short as short instead of long, how to properly report information, and how to properly manage it. In a free and transparent marketplace, every institution should have their cards on the table. If they want to invest, they should report it. If they want to short, they should report it. Naked short selling is illegal, yet reporting short positions at all is not something considered necessary? Do you seriously need a comment to point out how backwards that is?

FINRA 21-19 is a long overdue change. It is clear that the integrity of the United States market has been strained to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy. While many of the policies mentioned in Regulatory Notice 21-19 address the general breadth of exploitable and ineffective reporting, they also leave significant specific gaps that could compromise the entirety of 21-19's purpose.

More transparency in short positions is necessary for a fair market. There are currently too many methods of obscuring the real short interest of certain securities which creates an unfair environment for retail investors. FINRA should make more information about short sales public as well as investigate further into how synthetic shares are being created and hidden.

FINRA 21-19 is a long overdue change. It is clear that the integrity of the United States market has been strained to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy. While many of the policies mentioned in Regulatory Notice 21-19 address the general breadth of exploitable and ineffective reporting, they also leave significant specific gaps that could compromise the entirety of 21-19's purpose.

FINRA 21-19 leaves many problems with address general problems, but also makes many new ones that get rid of the purpose of 21-19. It is very important for the stability of the United States market that regulations regarding short positions are reported in every situation. Otherwise, short positions can go unaccountable for a long period of time after their due date. We must not let our standards fall enough to have investors lose influence in the US market and economy through acts of stupidity like this regulation.

As a Canadian Invested in US equities/stocks market. You need to review/change FINRA 21-19. It is clear that the integrity of the United States market has been strained to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy. While many of the policies mentioned in Regulatory Notice 21-19 address the general breadth of exploitable and ineffective reporting, they also leave significant specific gaps that could compromise the entirety of 21-19's purpose.

As a retail investor with over 15 years experience, I would like to urge FINRA to enact, with all haste, any and all new rules or amendments that make the American market more transparent and fair for all investors. For far too long the majority of investors have been in the dark in regards to short interest, robbing us of the ability to make informed decisions while researching and deciding on what trades to make. The system has been rigged in favor of the privileged few and it is time to bring this hidden data to light in the name of our supposed free and fair markets.

I for one am in favor of the enhanced reporting requires. An efficient market can only exist when accurate information is available to make informed decisions. As there is ample evidence of past and present naked shorting despite restrictions against it, requiring proper disclosures of large short positions, along with sufficient penalties to ensure accurate reporting is critical to identify the full extent of the problem and guide further rule making if necessary.